From 12 August 2026, PPWR Article 5 prohibits food-contact packaging from being placed on the EU market when per- and polyfluorinated alkyl substance () concentrations are equal to or above any applicable limit in Article 5(5), unless another Union act already prohibits that concentration. Start with scope, then preserve the sample identity, method, results, supplier proof, role decision, and Annex VII file needed for a release decision.
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Section 1
Start with the Article 5 PFAS trigger
Do not run review as a generic packaging-waste checklist. First decide whether the item is food-contact packaging that will be placed on the Union market on or after 12 August 2026, then record the packaging type, component boundary, economic-operator role, and evidence owner. Article 5 contains its own structural PFAS definition, so a supplier's narrower substance list or an unsupported 'PFAS-free' statement does not answer the PPWR test.
Commission guidance defines food-contact packaging for this purpose as packaging intended to be brought into contact with food, or already in contact with food and intended for that purpose, under EU food law. If the packaging is not food-contact packaging, keep the scope note and route the item to the wider Article 5 substances-of-concern and heavy-metals checks. If it is food-contact packaging, move directly to concentration evidence.
There is no PPWR stock-exhaustion transition for the limits. Commission guidance says food-contact packaging placed on the market after 12 August 2026 must comply even if produced earlier, while packaging placed on the market before that date may remain available without withdrawal. In general, the guidance treats sales and grouped food-contact packaging as placed on the market when filled, transport and service packaging as placed on the market empty, and imported packaging as placed when released for free circulation; record the actual transfer facts because legal possession can also establish the event.
Record whether the item is food-contact packaging and identify each packaging component included in the decision.
Record the first EU placing-on-the-market decision point and whether the 12 August 2026 Article 5(5) date applies.
Name the manufacturer responsible for the Annex VII technical documentation, any importer that must ensure the documentation can be supplied to authorities, and the supplier contacts that hold material evidence.
Attach the Article 5 source citation to the scope decision before requesting laboratory, supplier, or formulation evidence.
Collect PFAS concentration evidence against Article 5 limits
For in-scope food-contact packaging, map each result to the Article 5(5) limit it supports. Keep the analytical method, detection and quantification limits, sample preparation, sample identity, packaging component, result, unit, date, and decision owner together. Article 35 requires reliable, accurate, reproducible methods with low uncertainty; Article 5 does not turn a supplier declaration into a test method.
The Article 5 limit structure is not a single yes-or-no claim. Cover targeted PFAS results, the sum of targeted PFAS results where applicable with prior degradation of precursors, and the broader PFAS value that includes polymeric PFAS. Preserve the reported units and conversion basis; 25 ppb, 250 ppb, 50 ppm, and the 50 mg/kg total-fluorine evidence trigger are not interchangeable fields.
No harmonised EU method for in food-contact packaging has been adopted. For enforcement from 12 August 2026, the Commission recommends a stepwise approach: total-fluorine screening; if total fluorine exceeds 50 mg/kg, analysis to distinguish organic from inorganic fluorine; and direct total-oxidisable-precursor analysis for the 25 ppb and 250 ppb limits. The guidance says a sample below 50 mg/kg total fluorine could be considered compliant, not that this screening result changes the legal limits. Record the laboratory method and the guidance version instead of labelling the recommended sequence as a binding PPWR test standard.
Check 25 ppb for any measured with targeted PFAS analysis, excluding polymeric PFAS from quantification.
Check 250 ppb for the sum of measured as the sum of targeted PFAS analysis, where applicable with prior degradation of precursors, excluding polymeric PFAS from quantification.
Check 50 ppm for PFASs including polymeric .
If total fluorine exceeds 50 mg/kg, request proof showing the quantity of fluorine measured as or non-PFAS so the manufacturer or importer can complete the technical documentation.
Build the supplier-to-technical-documentation handoff
The evidence workflow should make supplier data usable by the manufacturer that draws up the PPWR technical documentation and by the importer that must ensure the file can be made available. Keep supplier declarations, test reports, formulation notes, and total-fluorine proof linked to the exact packaging component and packaging type.
Article 5 compliance is demonstrated in Annex VII technical documentation, and Article 16 requires suppliers to provide the manufacturer with information and documentation needed to demonstrate conformity. For total fluorine above 50 mg/kg, the manufacturer, importer, or REACH downstream user named in Article 5(5) must provide the requested proof to the PPWR manufacturer or importer for that file.
Procurement requests the supplier evidence package and records which packaging material or component it covers.
Product compliance checks whether the evidence covers each Article 5(5) limit and whether the units match the legal threshold.
The manufacturer stores the final scope decision, evidence, supplier proof, and approval in the Annex VII technical-documentation file; the importer keeps the declaration available and ensures that the technical documentation can be supplied to authorities on request.
If an importer has reason to believe packaging is not in conformity with Articles 5 to 12, the workflow should block placing the packaging on the market until conformity is restored.
Decision gates for release, escalation, and re-review
Close the workflow with a clear release decision rather than a vague status. The decision should say whether Article 5(5) applies, which evidence was reviewed, whether any limit value is met or exceeded, whether total-fluorine proof was needed, and where the technical documentation is maintained.
Re-review the decision when the packaging design, material composition, supplier, method, test evidence, or relevant Union restrictions change. Article 5 requires the Commission to evaluate by 12 August 2030 whether paragraph 5 should be amended or repealed to avoid overlap with restrictions or prohibitions under EU food-contact, REACH, or persistent-organic-pollutant law. That future evaluation does not suspend the 12 August 2026 PPWR limits.
Release: food-contact packaging is in scope, the Article 5(5) evidence package covers the required checks, and the Annex VII file is complete.
Escalate: any result is equal to or above an Article 5(5) limit value, total-fluorine proof is missing when needed, or another Union act already prohibits the packaging.
Out of Article 5(5) scope: document why the packaging is not food-contact packaging, then keep any Article 5 substances-of-concern or heavy-metals evidence with the broader packaging conformity file.
Re-review: refresh the record when the packaging, supplier evidence, conformity file, or relevant Union restrictions change.
Non-binding Commission enforcement guidance stating that no harmonised EU PFAS method exists for food-contact packaging and recommending a stepwise analytical approach.
Articles 5 and 15 support release and escalation decisions, the 2030 overlap evaluation, and reassessment after relevant packaging or specification changes.
"in a concentration equal to or above the following limit values"